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Constitutionality Of SDB Preference Still Undecided

Client Alert | less than 1 min read | 07.12.05

Expressing some frustration, the Federal Circuit in Rothe Dev. Corp. v. Dep't of Def. (June 28, 2005) remanded to the district court a second time for a determination of whether the latest enactment of the small disadvantaged business evaluation preference is constitutional, despite the price percentage bonus currently being suspended. The Federal Circuit repeated that the district court must apply strict scrutiny and must review evidence as to what Congress considered in establishing the preference.

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....